Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Assessment u/s 153A - completed assessments to be interfered with by the A.O. while making the assessment u/s 153A - The Tribunal upheld the decision of the Ld. CIT(A) in deleting the addition. - The ITAT reiterated the principle that completed assessments can only be interfered with by the AO under Section 153A based on incriminating material found during the search. Since the revenue failed to demonstrate that the additions were made on such basis, the court found no reason to interfere with the order of the Ld. CIT(A).
Assessment u/s 153A - completed assessments to be interfered with by the A.O. while making the assessment u/s 153A - The Tribunal upheld the decision of the Ld. CIT(A) in deleting the addition. - The ITAT reiterated the principle that completed assessments can only be interfered with by the AO under Section 153A based on incriminating material found during the search. Since the revenue failed to demonstrate that the additions were made on such basis, the court found no reason to interfere with the order of the Ld. CIT(A).
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